Christina DuVall is the Executive Director of Ethics, Compliance and Information Governance at Consumers Energy. Helping others is a passion for her and her journey is definitely unique.
Christina DuVall is the Executive Director of Ethics, Compliance and Information Governance at Consumers Energy. Helping others is a passion for her and her journey is definitely unique.
Bill Krieger: ...the views and opinions of the guests of the "Me You Us" podcast do not represent the views and opinions of Consumers Energy.
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Bill: Hello, everyone, and welcome to Me You Us, a wellbeing podcast. It's another wellbeing Wednesday here at Consumers Energy, and I'm your host, Bill Krieger. Today, my guest is Christina DuVall. She is the Executive Director of Ethics, Compliance and Information Governance. Christina, if you would introduce yourself, we'll get the conversation started.
Christina DuVall: Sure. Hello, everyone. Thank you, Bill, for having me on this podcast. I'm Christina DuVall as Bill said. I have the honor of working with our Ethics, Compliance and Information Governance teams. That also includes our CARAR, Compassionate Action, Restorative Action, Response teams as well.
I've been with the company over 25 years, so a very long time.
I grew up here, I'm happy to say. Just a little bit about me. I'm a wife and a mom and a great aunt and a sister and a daughter. I'm super‑family oriented. I was born to a military veteran who was stationed in Italy, so I was born in Pisa, Italy, and not the US. Dual citizenship, so that's pretty cool.
I feel like I have two homes that are both beautiful and wonderful to spend time in. That's me.
Bill: Do you have a great affinity for the Leaning Tower then? [laughs]
Christina: I was born in Pisa. About seven years ago, we did go to see the Leaning Tower because my last pictures there where I was like, six months old. It's very slippery. I feel like it's a safety hazard if you ever walked up to the top. [laughs]
Bill: Really? [laughs]
Christina: Oh, yeah. It's like marble steps that are really worn. I was afraid.
[laughter]
Bill: I'm glad that you made it back and made it back in one piece. That's a good thing.
Christina: Thanks.
[laughter]
Bill: Let's talk a little bit about compliance. When we were talking before the podcast, I had mentioned that I remember when compliance suddenly became important for the company. Listening to you talk, I think it was maybe even at a safety meeting at one point.
Now, I remember we didn't have a compliance department or compliance group. What happened that suddenly it was an important thing?
Christina: For our organization, although we did have a code of conduct that no one utilized or looked at. In fact, it's funny because the first code that they ever gave me had a picture of a compass on it that was pointing south. [laughs]
No real thought, I would say, went into anything. Round‑trip trading happened. During that period, as the company was investigating what our role is and all of that activity, as regulators were scrutinizing us, as lawsuits were popping up all over the place, it was a decision by the board of directors that we needed to start a compliance program and an ethics program.
The board had named our very first chief compliance officer to start looking at what needed to be true in order to avoid significant issues like round‑trip trading. Which for anyone that was here at the time, early 2000s, when that happened, you routinely heard it wasn't a compliance issue, it was an ethics issue.
We didn't actually break the law. We just didn't make decisions with the best of integrity. Having an ethics department seemed like the next step to maybe help people make better decisions, use better judgment when they were acting in the name of the company.
Bill: That's an interesting distinction between ethics and compliance. Compliance is more about rules and ethics is more about doing the right thing.
Christina: Yeah.
Bill: All right. I'm assuming that when you were born in Pisa and you were growing up as a young child, you didn't say, "Oh, gosh, I want to be a compliance officer when I grow up." What happened? How did you get here?
Christina: I would say growing up, there wasn't such thing as a compliance office or an ethics office. I wanted to be a marine biologist and study sharks off the coast of California at great white sharks.
Bill: Hold on. My sister wanted to be a marine biologist, too. Her and all her friends, it was dolphins.
Christina: [laughs]
Bill: I remember, dolphins were a big deal. For you, it was sharks.
Christina: Yes. I love dolphins, but sharks have a special place in my heart. I think they're wildly misunderstood. People think they're threatening and scary, when really, they're just them. That was my dream. Someday maybe, I'll still get to do that.
My son, who's 21 now and wants to be a doctor, we've made this deal that when he's finally done with school, we're going to go off the coast of Africa and do those shark dives in these cages with the great whites. We'll see. We might both chicken out, but that's the dream.
As I was working through my undergrad and looking for someplace to get some experience, I had an opportunity to join CMS Energy in Dearborn, which was the world headquarters in the late '90s and early 2000s.
I started in the IT department. In my head, I was going to transition to the environmental department and had a couple of interviews with environmental, but they never offered me a job.
Bill: Not a lot of sharks to deal with. [laughs]
Christina: Not a lot of sharks in the water. I never pictured myself working for a corporation. I always thought I would be a field biologist in some way or shape or form. I love outside, I love nature, and I love learning. That's my number one strength is learning. It was just interesting.
As I was working in IT, had a situation where the leader and the officer for my organization were engaging in some significant misconduct. They were embezzling from the company and it was everything from funds to equipment for family. It was pretty rampant behavior. I didn't know what to do and I didn't know where to go.
We didn't have a helpline, we didn't have an ethics department. The Dearborn office was where all of the officers were at the time. The leader that I worked for was really good friends that appeared with all of the officers. I didn't even feel safe going to one of the higher‑level leaders there. I didn't know what to do.
This is silly me, I could have left. If I would have known then what I know now, I think things would have been different, but it took me about a year and a half to come forward. When I finally did, it was horrifying experience if I can say that. I was terrified.
I remember having to meet an investigator in a lobby of a local hotel, so that we could have conversations in private, because no one knew what we should be doing or how we should be doing things. It added to the fear. It's like, "Can you get away from your job and be here at two o'clock?" [laughs]
I was like, "No, I'm being followed." It felt like a drama miniseries more than it felt like a professional working environment. When the investigation was over, I had decided that I couldn't handle working here anymore. I was a new mom at the time and I thought, "I need to start over."
I spent some time with this little guy who has just come into my life and put this behind me. I needed a break. It so happened that coincided with the whole round‑trip trading issue and the board's decision to appoint a chief compliance officer and he came to see me.
I was packing up the kitchen because they were closing the Dearborn office. Ponytail and jeans which you did not wear in Dearborn, totally not professional attire. He asked if he could interview me for a role. We talked for 30 seconds, and then he was like, "I want you to come and join my team. Stay for a year.
I know that you've put in your resignation, but help me start to build a program so no one has to go through what you went through." I didn't even pause. I was like, "OK, I'm in," which signed me up for a very long drive to Jackson every day, but I was like, "I'm only doing this for a year." I think that was famous last words.
I've been in this role [laughs] for a very long time, and it is my heart song.
Bill: It's very important to realize that it's one thing to have things going wrong. It's another thing for a company to recognize it and then reach out to folks and bring them along. What a great way to look at it to say, "Here's someone who was essentially a victim of our lack of any process, let's have them come in and help fix this."
Christina: When you report there's always this concern, "I'm going to be labeled. This is going to be career defining for me, or something really, really bad is going to happen to me. They're going to find a way to make sure that I don't work here anymore." That's scary because it's your livelihood.
I was the primary earner in our family at the time, and losing my job was a significant impact. It was a family decision when you put your resignation, and I totally get that. I know that that's where all of our coworkers are. That wasn't my experience. I was shocked beyond belief to have this officer who I knew and respected comment and offer me this program.
Then even more shocked the first meeting I was in with multiple officers to talk about what this was going to mean, all of their respect and support and just care. I think sometimes as coworkers we get this impression that leaders maybe don't, they know what's happening or they're supportive or they're looking in the other way because of who an individual might be.
That has never been my experience with any of the situations now in my multiple years in this role, but new to this role. I was really, really surprised and pleasantly surprised and felt so valued. Then I felt silly because I recognized how wrong I was and how judgmental maybe [laughs] I was through the whole situation.
Bill: When we find ourselves in those situations, the first thing that we think of maybe is self‑preservation, so it's nice to know that right from the beginning we took care of that. As a company, I've been here 28 years, so we've got similar time here. The company has always to me been ethical. We've had people who have had lapses.
It's good to know that now we have guidelines. As this podcast comes out during Ethics and Compliance Week, it'd be great to have a conversation around how we went from...if we look at it in today's standard where we have hardlines, guidelines and no lines, we were wild wild west back in the day with no lines.
Maybe a few guidelines, but our compass was pointed in the wrong direction as you pointed out to where we're at today. How did that all evolve? The other question is, as that was evolving, did you have those days where you're pulling your hair out going, "Oh, how do we get this done?"
Christina: [laughs] I still have those days where you're like, "How do I get this done?" That never goes away. It was shortly after the appointment of our chief compliance officer that some regulations started to get passed in the wake of Enron and round‑trip trading and things like that, that mandated compliance officers for public companies.
There were board guidelines that were passed. Regulations started to require this for not only our industry, but any publicly traded company as a whole.
What that opened the door for was a whole lot of research and support, almost like this broad family of individuals across the nation who are trying to figure out together, what does good look like when you're thinking about ethics and how do you build a program.
I never felt alone and there was a wealth of philosophy and research and benchmarking that was available. National Ethics and Compliance Week actually aligns with the Department of Justice's guidelines for organizations on what they considered to be a good ethics program.
That focuses on things like tone at the top and having mechanisms to support coworkers coming forward and processes to look into what their concerns might be and how even we respond to those.
Those are guidelines, so those aren't hard fast rules, but it helped to shape thinking and it allowed for more structured conversations with our decision makers about what good looks like for us. The first start was, we need helpline, we need to give coworkers a resource.
We set up this helpline but we had no processes like what happens when a coworker files a concern. It was up for one day and someone called the very first call ever and it was, "Hey, we have a coworker who's retiring. They've been here like 35 years or something like that. They keep coming back and forth to the headquarters filling the back of their pickup truck."
I will never forget [laughs] this concern. I was like, "OK, maybe they have a lot of stuff." [laughs] It was like, "They don't even have their own desk, so how do they have three loads of stuff that they're taking with them?" I had no idea what to do with that concern where to even go.
I was from the non‑utility side, the CMS Energy World headquarters at the time, so I didn't even know utility leaders. That was all something that we had to learn and grow in. It became clear right out of the gate having a process and a path to help coworkers was the primary goal that we needed to focus on.
We did other things like rewrite the code and start to build programs and processes, expand oversight and start to create transparency for the board and our officer teams, but it was trying to figure out who we are and what we wanted to focus on as an organization in the space of ethics.
What did our leaders need from us and what did our coworkers need from us. I always felt like I was helping. I was there to listen and figure out the best way to get to good that helped everyone and that was pretty rewarding.
Bill: I don't think there's anything better than having a job where you know what you do is going to make a difference for people in the long run in a good difference. It sounds to me like there were a lot of best practices followed and that this was not built in a vacuum. Those are all very good things. I want to talk a little bit.
We have the compliance line that you can call when you have a concern and we talk a little bit about, even from your experience, how scary that can be, even with anonymity and I'm calling this 800 number and I'm reporting whatever this is. There's that side of it where I'm very nervous about this.
There's the other side of the person who is being investigated which can be a very scary proposition. Let's talk about that for a minute and how do we do this in a way that makes people still feel valued?
Christina: Whenever you're talking about concerns, regardless of what role you may play in the concern, the reporting party, a witness, the person who's accused of wrongdoing, the level of fear that is just natural, it's part of human nature is overwhelming. It's something that my team and I never lose sight of.
We always start with how can we alleviate some of that concern in here? I've reported concerns so I know firsthand how hard that can be, how scary that can be for coworkers. I've also been reported, which might surprise a lot of our coworkers.
Bill: Wait a second, the compliance person that reported? Wow. [laughs]
Christina: It was a number of years ago and happily it was not true, it was unsubstantiated. It was someone's perception of me that led them to file a concern about relationships that I might have had in the workplace.
It might not be intuitive to coworkers, but our review process also has conflicts of interest like protections in place. If there's a concern that comes in against the ethics and compliance team, the ethics and compliance team does not review that concern. [laughs]
Bill: That's very good to know. We're not investigating ourselves.
Christina: No, we never investigate ourselves. There are processes in place and it goes to a different area for that review so that it can be independent and impartial. For my concern, it came through the helpline. I did get to see it and you hand it off, but I was devastated.
I went home that night and [laughs] drank a gallon of milk as hot chocolate because that's my vice. Mortified that someone could think that way of me and wondering what I did that created that perception. I was heartbroken and I was terrified. I was like, "How can I even be in this role when this situation was just reported?
I'm supposed to be managing the ethics function for the company, and this says I have no ethics." It was really, really hard, and I had to wait.
Like, "I'm supposed to be managing the ethics function for the company, and this says I have no ethics." It was really, really hard, and I had to wait. That was also hard.
Then I felt like significant amounts of shame. I had to come in and still do my job every day and work with high‑level leaders and coworkers across the organization, and I'm supposed to be speaking on ethics and I felt like that had been called into question.
It seemed like a heavy ask to be able to hold my head up and stand in front of coworkers and talk about why we have an ethics and compliance department when I didn't think that people believed that I needed to be there. It was challenging. The actual investigation if you will, itself was fine.
When I finally sat down and spoke to the person who is assigned to do the review, she was wonderful, and she was kind and caring and helped me put it behind me. It took a minute to get to that, and it was those few days. I think it was like three days. I was in this different zone. We don't lose sight of that either.
Our investigation processes we call it more a review than an investigation, but it's called compassionate action, restorative action. It's built with the thought that we aren't managing transactions, we're working with people, we're helping coworkers.
Regardless of whether you're the leader, the reporter, the accused, a witness, a bystander, you have feelings and concerns and all sorts of emotions tied up into this. We need to be mindful of that and understand and understand root cause, so that we can truly help in the way that we're supposed to, and enable everyone to move beyond.
Bill: When an allegation is put forward, even if you didn't do anything and you know that you didn't do anything, like you said, there's this thought in the back of your head, like, "What did I do to make that perception happen?" Probably, in all likelihood, you probably didn't do anything, but you start to question yourself.
In a way, it was terrible that that happened. In a way, that was good, because it really puts you in the mindset of all parties.
Christina: Yeah.
Bill: When we talk about Cara and how we're looking at reviews, voice investigations, we look from a holistic point of view. Like you said, from the reporter, from the accused, from the people. Anyone who's involved in it. Then how do we handle that going forward?
Many times, the allegations are unfounded. That doesn't mean that that person didn't perceive what they perceived. It just means that when we looked at all the facts, it was a wrong perception.
Christina: Yes.
Bill: There's that. Then there are times where the allegation is founded and then action has to be taken. How do we look at that? We talk about safety. I know that for years, we talked about physical safety. Slips and falls. Making sure that we're wearing our hard hat, our safety glasses, our gloves, and all of that PPE that we have.
Then we've turned the conversation to psychological safety. How do we protect the psychological safety for all parties involved in these reviews?
Christina: Yes. Recognizing that sometimes it takes a Herculean effort for co‑workers to come forward and to share and report a concern. Research tells us we only really hear about 20 percent of what's happening in the organization because coworkers are not coming forward.
There's all kinds of research about how to make it safer and the ethics space. How to publicize your helpline so that it's readily available so that they can do that. Focus on bystander. You'll see a lot of that in our communications. Psychological safety goes beyond that.
We've built retaliation monitoring programs because I know coworkers are concerned. We wanted to make sure that we found a way to help them work through a lot of the emotion and the fear that occurs post a concern. The retaliation monitoring does that. It allows us to do all these check‑ins.
We do things like evaluate PEFD ratings, merits, assignments, and all kinds of stuff in the background for anyone involved in the process, just to make sure that there isn't anything that's happening in that space.
Then we check in to make sure that the relationship side is moving in the right direction as well. We do stick with coworkers, but that's a process. That's reactive versus proactive. It doesn't actually help coworkers feel confident to raise their hand.
We started exploring this concept of psychological safety because it goes well beyond reporting a concern. I hope coworkers never experience anything where they have to report, but we tried every avenue to make sure that they would be safe in that channel. Psychological safety extends beyond reporting concerns.
It's feeling like you can share your voice in any capacity. It's whether you have opinions and ideas about where the company should go or how a process could be improved, it's about whether or not you feel like you could be the naysayer to something that someone else has proposed or leadership has proposed or whatever it might be, or if you've identified problems.
When you think about waste elimination or safety or any of our compliance processes, things are going to happen. People are going to make mistakes, things are going to break, weird things happen sometimes. Being able to raise your hand and stop the job on a safety thing, that's psychological safety.
You should be able to do the same thing when you see an ethics or a misconduct issue, be able to raise your hand stop the job. It doesn't feel right, maybe we need to pause and see if there's an issue here.
Also being able to in a room when you're sitting there with your team talking through how best to change a process, being able to have your voice and feel valued there too, that's at the heart of our DENI effort as an organization. Psychological safety is critical for a company to succeed on so many fronts.
It's creating the cultural environment so that coworkers can do that. Now, that doesn't mean that everyone agrees, and it doesn't mean that everyone's like best friends and best buddies in that space, but it's being able to have candor to share your voice and to not feel that there's a risk to you in doing so.
It gets beyond that little personal risk assessment. Sometimes I do this too. Everyone in this room is a lot smarter than me, so they must know what they're talking about and I am not going to raise my hand. That is human nature. I bet we've all felt that.
Psychological safety says, "Even though I may not be as smart as everyone else in this room, I am going to raise my hand too, just in case someone hasn't thought of this." It's to those individuals who take that extra leap, that's how better ideas come forward. That's how problems are identified and resolved.
That's how we're stronger as an organization. To me, that's inclusion.
Bill: We talk about diversity of thought and how we get better outcomes when we hear from people with differing opinions. It's important to remember, though, raising your hand and having a differing opinion, we still have to be respectful of other people's opinions as well, because at the end of the day, it's all opinion. Nobody has the market cornered on being right.
Christina: Absolutely. We look to leaders too, to create that environment where opinions are respected, but where you still have to make a decision too. If everyone disagrees [laughs] at the end of the day, someone's got to decide what direction we're going to go. Just because your opinion wasn't the direction that went, that also does not mean that you are not valued.
Bill: I think that's very important for people to understand is that, yes, we value your opinion and sometimes it's going to be implemented and sometimes it's not. I like this to my time in the military. As a commander, I had what's called a first sergeant.
My first sergeant was to me like the union leadership, because he really represented all of the working folks in a unit. We would always say that when we come out of my office, we're going to be marching in the same direction, but while we're in my office, we're going to disagree on things.
Sometimes he prevailed and sometimes I prevailed but at the end of the day, we knew we respected each other's opinion and position, but we still had to get work done.
Christina: We use this concept of psychological safety and collaborative thinking and everything that the Ethics and Compliance Office does, everything.
If you send a question to the PO Box before we send a response, we're aligning with subject‑matter experts and whoever we might need to about what that response should be, even when we already know the answer, just to make sure that something hasn't changed. When we handle employee concerns, it's a collaborative group.
We call it the CARAR Collaboration Team that gets together to think about and review all of the facts, what the issues were, and talk about what root cause might be and what truly needs to be in place to address the needs of coworkers. It's never done in a vacuum. It's never one person making recommendations.
It always is a collaborative group, each with their own thoughts and ideas and risk lenses that they bring to the table to make sure that we're looking at every situation from every possible angle. I totally value that team. I love that we're here and it's something that most organizations when we benchmark cannot figure out.
We're a little unique in that space and we've been doing it that way since 2006. Special call out to that group, I love you all. Totally appreciate you. [laughs]
Bill: Shout out to that group. We did mention Ethics and Compliance Week. I did want to ask, do we have some things going on for that?
Christina: We do. It's going to be so much fun. It'll be a little bit passive, I think mostly because we know that our coworkers have a lot going on and we don't want to add to the information overload and the stress, but we are standing up a special SharePoint site that's going to have all kinds of cool things.
There's going to be a neat video featuring our CEO and our chief compliance officer, so Garrick and Melissa and Sean Johnson, our general counsel. I'm really excited for that. I don't want to give away too much, but we're thinking of basing it off with some popular sitcoms, so [laughs] it's going to be cool. I'm super excited.
We're going to have some special messaging from our canine care companion archer, so he's our little corgi who is a member of my team as well, so he'll be showcased. There'll be a cool game with an opportunity to win some prizes and some interesting information about the Ethics Compliance Team.
If you're curious on getting to know us as human beings a little bit more instead of that scary group that isn't so scary at all. Then anonymous will be front and center. It's going to be a lot of fun. We're also looking at which will be Q3.
We're going to extend our Ethics Week stuff for a few months, putting together a game show for our coworkers. I think that's going to be a lot of fun too. Our rough draft title is who wants to avoid a million dollar fine?
[laughter]
Christina: They take you where you want to go.
Bill: That's nice. I like that.
Christina: Everyone raise your hand.
[laughter]
Bill: It sounds like a lot of exciting things. Now, a lot of people don't know this about me, but one of my very first jobs, I was actually Chuck E. Cheese. If you're looking for someone to be anonymous at some point, please let me know.
Christina: We may take you up on that. [laughs]
Bill: I also did a little stint as McGruff the Crime Dog.
Christina: Oh, really? [laughs]
Bill: Yes. I have some experience of being a mascot.
Christina: We might take you up on that. [laughs]
Bill: You know how to get a hold of me.
Christina: The custom's a little hot. [laughs]
Bill: Well, Christina, this has been informative. As always talking with you has been a lot of fun. Our audience will get some better understanding about ethics and compliance and how that works for all of us. We are getting close to the end of the podcast, but before we go, I'm wondering, what would you like the audience to take away from our conversation today?
Christina: That you're important, that your voice matters in every capacity. If you don't find a way to share your voice, especially when it comes to raising concerns about misconduct or ethics issues, the likelihood of them being resolved is very, very small. We need you. We need you to be the help of bystander.
We need you to care about the company and your coworkers and yourself and do the right thing. When you do, we are going to be here for you. It's not intended to be scary. I know it's a little challenging to take that completely away, but me and my team, we're here for you, and you can call us at any time and we'll walk through those fears with you and help to get to a good place.
Bill: All right. Thank you for all of that.
Christina: Thank you for having me. This has been lots of fun.
Bill: I get the feeling maybe we'll be doing this again. This has been a great time. Thanks again for coming on.
Christina: Thank you so much. Take care, everyone.
Bill: Thank you to the audience for listening in today. The "Me You Us" podcast is proudly sponsored by Consumers Energy, leaving Michigan better than we found it. Remember, you can find the Me You Us podcast on all major podcasting platforms. Be sure to go out, find us, and subscribe.
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